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Reimbursement for Database Usage Costs Not Classified as Royalty Under Indian Tax Law.
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....Income deemed to accrue or arise in India - reimbursement of cost - once the payment made for the usage of the database does not fall within the ambit of Royalty, recovery of costs by the assessee from the associated enterprises for the usage of the database cannot also result in Royalty in the hands of the assessee. - AT....